Article 15 of the OECD Model: The 183-Day Rule and the Meaning of ‘Not a Resident’ in Cases of Hybrid Partnerships - Intertax View Article 15 of the OECD Model: The 183-Day Rule and the Meaning of ‘Not a Resident’ in Cases of Hybrid Partnerships by - Intertax Article 15 of the OECD Model: The 183-Day Rule and the Meaning of ‘Not a Resident’ in Cases of Hybrid Partnerships 41 10

Article 15(2) of the Organisation of Economic Co-operation & Development (OECD) Model is important in taxing employment income from a shortterm assignment of employees and the hiring-out of labour. This article examines whether, for purposes of the 183-day rule, the employer needs to be a resident of a state and how conflicts regarding the employer status of hybrid partnerships can be solved.

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